Written evidence from Blaby District Council
Blaby District Council welcomes the opportunity to
have greater control over the development of its area. The Council
considers that it is best placed to understand the needs and desires
of its communities and that housing requirements imposed from
a National or Regional level may not fully appreciate local circumstances,
desires and constraints that exist within Blaby District. Regionally
imposed targets have not given Local Communities adequate opportunity
to become engaged in the process of developing housing targets.
Notwithstanding this broad support, the Council wishes
to highlight some concerns associated with the "immediate"
revocation (and subsequent abolition) of the Regional Plansparticularly
in relation to housing delivery.
1. The revocation of housing provision figures
(within Regional Plans (RSS)), coupled with the retention of a
requirement to provide a five year supply of housing (as defined
in Planning Policy Statement 3) and the presumption in favour
of residential development where a five year supply cannot be
demonstrated (paragraph 71 of Planning Policy Statement 3 (PPS3))
may result in uncertainty.
2. The "Question and Answer" guidance
issued by CLG on 25 June 2010 (accompanying CLG announcement revoking
Regional Plans) identified that Local Authorities may use "option
one" figures as a housing target in the interim period before
more robust evidence is gathered. There is some ambiguity as to
whether "option one" figures refer to the level of development
sought by Local Planning Authorities as part of the submission
to the Regional Plan or the level of development included in the
draft Regional Plan (considered at Examination). The latter level
of growth being that supported by the section 4(4) Authority (Leicestershire
County Council). This should be clarified.
3. Government announcements have indicated
that Local Authorities have the ability to determine their own
housing requirements. This has raised considerable expectations
amongst Communities that the level of growth contained within
the RSS (which is perceived by many as too high) could be reduced.
Notwithstanding this, the guidance from CLG indicates that any
alternative figure must be robust as it can be tested at examination.
The extant Planning Policy Statement three indicates the sources
of data that should be used to inform housing need. It is possible
that the identified need arising from such sources could exceed
the targets in the previously abolished RSS (even if they are
derived "locally"), this could result in animosity from
Local Communities if they perceive that even greater numbers are
4. Blaby District Council has struggled
to meet its housing targets in recent years. It is likely that
the main factors influencing slow housing delivery are the international
economic downturn and credit crunch rather than the failings of
the Planning system. It is possible that too much emphasis could
be placed on the role of RSS targets in suppressing housing supply.
There is concern that revocation of the RSS may further reduce
housing delivery as developers are cautious about submitting schemes
in the absence of clear housing requirements and guidance.
5. The Regional Plan not only contains policies
relating to housing numbers, but also sets out important strategic
guidance relating to distribution of development, employment,
flooding, transport, climate change and renewable energy. The
revocation of RSS has resulted in a detailed policy vacuum on
these topic areas.
There needs to be clarity regarding the "incentives"
(New homes bonus (NHB)) to encourage new housing development:
Whilst the level of incentives to be allocated appears
to be based on a multiplier of the Council tax achieved from new
housing development, it is unclear whether monies will be given
to the communities/neighbourhoods that are directly affected by
development (for example the Parish/Town Council whose area is
affected by the proposal); whether the money is to be paid to
the Local Planning Authority, or; the money is to be distributed
in the same way as the current Council tax with the majority going
to the Upper tier authority. It is apparent that the direct "local"
benefits are reduced in the latter options.
There needs to be further clarity as to how the NHB
can be spent. It is understood that it will not be "ring-fenced"
and could be absorbed into the wider Local Authority budgets.
This may suppress the overall Council tax requirements per capita,
but may not be of any direct benefit to local communities affected
It is unclear if the NHB payments will be paid at
the grant of planning permission, start of construction or completion
of new dwellings. It is also unclear if payments would continue
for a period of six years from formal announcement of the scheme
or a rolling six year programme.
One of the primary reasons for revoking Regional
Plans was to return decision making to local councils (including
on housing numbers). As mentioned above, the housing aspirations
of local citizens, neighbourhoods and communities may not match
those that are being identified as part of the gathering of "reliable
evidence". If the housing numbers sought by the local community
are significantly below those identified by evidence it could
raise false expectations, particularly communities that are subsequently
incapable of being defended at Planning appeals and examinations.